When Planning Decisions Rely on Strategic Evidence but No Local Assessment Exists

When a local planning authority determines an individual application, the law does not ask whether strategic evidence exists somewhere within the authority’s evidence base, or whether impacts could theoretically be assessed at a later stage.

The critical question is narrower and more exacting:

At the point of decision, had the authority actually assessed the impacts it relied upon, at the scale of the proposal and the affected community?

Where the answer is no, a recurring procedural problem arises that is often overlooked in committee decision-making.

This page examines how reliance on district-wide or plan-level evidence can mask the absence of site- or community-specific assessment, why this matters in public law terms, and how the issue commonly passes unnoticed.

Strategic evidence and application-level assessment are not interchangeable

Local Plans are supported by extensive evidence bases. Transport modelling, sustainability appraisals, flood risk studies and housing needs assessments are routinely prepared to inform plan-making.

Those documents answer strategic questions, such as whether growth is acceptable in principle across a district, or how competing objectives are balanced at policy level.

They do not, by themselves, answer the different question that arises at application stage:

What is the impact of this proposal, at this location, on this community?

That question requires assessment at application scale. Treating strategic evidence as a substitute for such assessment is not a matter of planning judgment; it is a mismatch between the scale of the evidence and the scale of the decision.

What counts as evidence of an assessment

For decision-making to be procedurally fair, it is not enough that information exists somewhere within the authority’s possession. There must be evidence that an assessment actually took place.

An assessment requires three elements:

Identification of the issue requiring evaluation
Application of an evaluative process to the specific proposal
A reasoned conclusion capable of supporting the decision taken

Consultation responses, policy citations, or statements of concern do not satisfy this requirement. Nor does reliance on evidence produced for a different purpose at a different scale.

If there is no document, analysis, or recorded reasoning demonstrating that an issue was evaluated at application scale, then in legal terms no assessment has occurred.

How the absence of assessment is obscured at committee

In committee reports and presentations, the absence of site-specific assessment is rarely stated openly.

Instead, it is commonly obscured through language such as:

“the proposal raises concerns”
“there is conflict with policy objectives”
“insufficient comfort has been provided”

Members are not directed to any assessment demonstrating how the alleged harm was evaluated, nor are they told that the material relied upon is strategic rather than decision-specific.

As a result, members are invited to determine the application on the basis of assumed impacts rather than assessed ones.

Committee members and procedural exposure

Planning committee members are entitled to rely on officers for accurate advice on evidential matters. They are not trained in public law, nor are they expected to distinguish between strategic evidence and application-level assessment without assistance.

Where officers do not identify the absence of site-specific assessment, members are placed in a position of procedural exposure without realising it.

This is not a failure of members. It is a governance failure in how evidential status is presented to the decision-maker.

Why this engages procedural fairness

Procedural fairness requires that an affected party can understand the basis of a decision, see what material was relied upon, and meaningfully challenge it.

Where no site- or community-specific assessment exists, none of those things is possible. An applicant or affected community cannot challenge an assessment that was never undertaken.

If the true basis of the decision is an assumption drawn from strategic material, but that fact is not disclosed, the decision-making process becomes opaque.

Opacity of this kind is not a minor defect. It goes to the heart of procedural fairness.

Why the issue is rarely confronted later

At appeal stage, new evidence is often introduced and impacts may be assessed for the first time. The focus shifts away from what was done at decision stage to what can now be resolved.

This can correct outcomes, but it does not retrospectively cure a failure to assess impacts before public power was exercised.

As a result, the absence of decision-stage assessment frequently disappears from view, even though it was present at the moment the decision was taken.

A closing observation

This is not an argument about planning merits, nor about whether development should or should not proceed.

It is a question of whether a local planning authority can lawfully determine an application on the basis of impacts it has never assessed, while presenting strategic material as if it were decision-specific evidence.

That question goes to the integrity of the decision-making process itself, and it is one that deserves far closer scrutiny than it usually receives.

PGAT

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